Volume 01 · 2026
The Counterparty
Financial Crime Intelligence for Practitioners · By Benjamin Dunlap
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Issue 09 · BSA / AML Watch · 26 June 2026
De-Risking Does Not Reduce Money Laundering Risk. It Relocates It.
When a correspondent bank cuts off a respondent or an entire customer class, the underlying activity does not vanish — it moves to corridors with less visibility. What the FinCEN Files data shows about the gap between paper compliance and real effectiveness.
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Issue 08 · Enforcement Watch · 25 June 2026
The DOJ Now Wants Evidence Your Compliance Program Works, Not Proof It Exists
The DOJ's updated Evaluation of Corporate Compliance Programs now asks whether compliance has timely access to quality data, and it created a Counsel for Compliance and Data Analytics to press the point. Four takeaways for CCOs.
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Issue 07 · Anti-Corruption Watch · 19 June 2026
The EU Now Treats a Paper Compliance Program as an Aggravating Factor
The EU's new Anti-Corruption Directive adds a trading-in-influence offense, fines up to 5% of worldwide turnover, and extraterritorial reach. For US companies with EU exposure, the gap analysis should start now.
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Issue 06 · Cross-Border Investigations · 19 June 2026
A Clean Database Result Is Not a Clean Counterparty
The first document set a client produces is the one they feel comfortable producing. In cross-border work, scoping matters more than analysis, and a clean database result is not a clean counterparty.
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Issue 05 · BSA / AML Watch · 08 June 2026
A Filing Instruction Is the Easy Part of FIN-2026-A002
FinCEN's June 2026 advisory reads like a SAR-protocol change. It is the opening move in a compressed regulatory sequence most BSA programs are not built to absorb.
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Issue 04 · Enforcement Watch · 08 June 2026
The Self-Disclosure Window Is Closing, and Most Programs Are Built to Miss It
The DOJ's new self-disclosure policy rewards speed. Most compliance programs are designed for an enforcement environment that no longer exists.
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Issue 03 · Americas Risk · 01 June 2026
The Compliance Program That Sees One Country Misses the Network
Financial crime in the Caribbean Basin does not respect borders. Compliance programs that ask the country question miss the network question.
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Issue 02 · Americas Due Diligence · 28 May 2026
The Most Expensive Part of the Deal Was Not on the Term Sheet
Pre-acquisition financial crime due diligence is consistently the most under-resourced component of cross-border deal work.
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Issue 01 · GCC Financial Crimes Risk · 27 May 2026
Grey List Removal Does Not Mean the Risk Went Away
Grey list removal reflects legislative progress. It does not measure whether financial crime risk has decreased.